The First District of the Illinois Appellate Court, in Saletech, LLC v. East Balt, Inc. et. al., 2014 IL App (1st) 132639, https://www.state.il.us/court/Opinions/AppellateCourt/2014/1stDistrict/1132639.pdf, upheld a decision that a distribution agent who claimed that the European parent of a Ukrainian subsidiary had agreed to implement an exclusive US distribution rights deal with the Ukrainian subsidiary in exchange for proof of fraud by the subsidiary’s management had failed to state a legal case for breach of contract against that parent company or against the European company’s American parent. Parent companies, even though they own 100% of subsidiaries, are not liable as “alter egos” of their subsidiaries, or as agents of their subsidiaries, and the offer to implement a deal if fraud was proved was not enough to show ratification of the subsidiary’s deal by the parent sufficient to make the parent liable for the subsidiary’s contract.